
107
easyJet plc
Annual Report and Accounts 2023
Strategic report Financials
Governance
COMMITTEE REPORTS (CONTINUED)
AUDIT COMMITTEE REPORT (CONTINUED)
The Committee received updates on the progress
made on the framework as well as issues identified
as a result of deep dives followed by mitigating
actions. In addition, the Committee agreed that
anti-fraud procedures would be reviewed in FY24
to make enhancements where possible to
minimise the risk of fraud offences to ensure
compliance with forthcoming enhancement to
anti-fraud legislation.
Internal Audit
The Committee is responsible for overseeing the
work of the Internal Audit function, which provides
independent and objective assurance to
management, the Committee and the Board on
the effectiveness of the Group’s risk management
and internal controls. The purpose, scope and
authority of Internal Audit is defined within its
charter which is approved annually by the
Committee. To safeguard independence, the
Director of Risk & Assurance has a dual reporting
line into the Chair of the Audit Committee and
CFO, and can meet privately with the Committee
without management. External providers can
be engaged where specific skills are required.
The Internal Audit function will undergo an
independent External Quality Assessment in
early FY24.
The Committee reviews and approves the scope of
the Internal Audit annual plan and resourcing levels.
Increased focus on financial processes and controls
was included in FY23 and future audit plans. The
Committee reviews continuous improvement in
audit methodology. Members have access to
detailed Internal Audit reports. It assesses the
quality of Internal Audit reports and considers
management’s actions to address findings.
At each Committee meeting, an update is received
on progress against the Internal Audit annual plan
and the status of the closure of recommended
actions.
The Committee received detailed updates on
audits with limited assurance and recommended
action plans and management responses. The
Committee also considers stakeholder feedback
on the quality of Internal Audit’s work.
The Group is committed to the highest standards
of quality, honesty, openness and accountability.
The Code includes a provision that there should be
a means for the workforce to raise concerns and
that the Board should routinely review this
mechanism and the reports arising from its
operation. The Group and all operating companies
have whistleblowing policies in place and the
Board and Committee receive regular reports on
this subject, which is communicated internally as
the ‘Speak Up, Speak Out’ (SUSO) mechanism. The
Committee assists the Board in ensuring that
adequate arrangements are in place for the
proportionate and independent investigation of
such matters and for appropriate follow-up action,
with trends being regularly reported to the Board.
Employees are encouraged to raise concerns under
the policy and any concerns raised are investigated
carefully and thoroughly to assess what action, if
any, should be taken. All employees are able to
report concerns in their local language. The
Business Integrity Committee is a management
forum on whistleblowing. It receives summaries of
all reported concerns; it monitors any ongoing
concerns and ensures that the proposed outcomes
of investigations are fair, transparent and robust,
with root causes identified and remedial actions
agreed. Any matters of significance are reported to
the Committee and the Board, along with a
comprehensive full-year report.
As a result, the positive increase in SUSO cases
continued in FY23, with a total of 233 cases
received, compared to 105 cases in FY22. All
reports were followed up, triaged to relevant areas
of the business and investigated where
appropriate. The Committee was pleased to see
both the increased use of the whistleblowing
channels and appropriate action taken for
underlying themes.
To ensure mitigation against fraud risks,
management has conducted deep dives into the
Group’s Anti-Bribery and Corruption Framework
and has plans to launch a wider fraud investigation
framework across the Company in early FY24.
To ensure the robustness of our financial controls, a
financial control improvement programme was
launched in the previous financial year.
Management has completed the documentation of
key financial processes and is now working to
implement control improvements which were
identified through this exercise. Management has
also worked with BDO to implement a system
which will facilitate the ongoing monitoring of the
operation of key financial controls, through a
combination of self-certification (or attestation) by
control operators and independent testing of the
operation of controls by appropriate compliance
teams. The system was implemented just before
the year end with the intention that all control
operators will be self-certifying on the system by
early 2024. The Committee will undertake regular
reviews of the effective operation of these key
financial controls in the forthcoming financial year.
In the meantime, the updates provided to the
Committee during the year confirmed that no
significant control gaps had been identified and
there were no known breakdowns of critical
controls in the current financial year.
As a result of this annual review of the
effectiveness of the risk management and internal
control systems, which the Committee undertakes
on behalf of the Board, it is considered that the
Board has fulfilled its obligations under the Code.
Further details on the Group’s principal risks and
uncertainties and their impact on the prospects of
the Group are set out on pages 61 to 66.
Compliance, whistleblowing and fraud
To strengthen the Compliance and Assurance
function in FY23, management had embedded a
compliance and assurance framework. This
included the development of a Group-wide policy
management framework for management and
assurance of policies across the organisation. It
also covered the development of a supplier
relationship management framework to identify
how our suppliers comply with our policies initially
and on an ongoing basis. The Committee received
regular updates on the progress made against the
compliance and assurance framework.
External audit
PwC, as the external auditors, is engaged to
conduct a statutory audit and express an opinion
on the Group’s financial statements.
During the year, PwC presented the strategy and
scope of the audit undertaken as well the areas of
focus providing an opportunity for the Committee
to monitor progress and raise questions. PwC
shared insights and feedback with management
and refined the planned audit approach for the
financial year ended 30 September 2023.
Following the retirement of Owen Mackney, he was
succeeded as external audit partner by Matthew
Mullins, Senior Statutory Auditor with the
responsibility for signing the audit opinion on
behalf of PwC. The external audit plan and the
£1.87 million fee proposal for the financial year
(2022: £1.1 million) was prepared by PwC and
presented to the Committee for consideration and
approval.
External auditors effectiveness
The Audit Committee is focused on ensuring the
external auditors deliver a high-quality audit and
plays an essential role in overseeing the Group’s
relationship with the external auditors to ensure
their independence, the quality of the external
audit process and provide challenge where
necessary. The Committee has regular
engagement with the external auditors, including
meetings without any member of management
being present, as well as ahead of each
Committee meeting. It also assesses the
effectiveness, independence, objectivity and
quality of the external auditors by reviewing,
among other things:
> The audit approach, key areas of focus, scope
and level of fees for the audit.
> All key external auditors plans and reports; in
particular those summarising audit work
performed to address significant risks and
critical judgements identified, and detailed audit
testing thereon.
> Quality, knowledge and expertise of the Audit
Engagement team, the nature of their interaction
with management and Audit Committee
members, and the culture they display.